Page 95: http://www.cfapubs.org/doi/pdf/10.2469/ccb.v2005.n3.4000 “Commingling compliance procedures in the firm’s code of ethics will diminish the goal of reinforcing with the firm’s employees their ethical obligations. Stand-alone codes of ethics should be written in plain language and address general fiduciary concepts, unencumbered by numerous detailed procedures directed to the day-to-day operation of the firm. In this way, codes will be most effective in stressing to employees that they are in positions of trust and must act with integrity at all times. Separating the codes of ethics from compliance procedures will also reduce, if not eliminate, the legal terminology and boilerplate language that can make the underlying ethical principles incomprehensible to the average person. Above all, the principles in the codes of ethics must be accessible and understandable to everyone in the firm to ensure that a culture of ethics and integrity is created rather than merely a focus on attention to the rules.” T/G
Excellent, Smithers.
See Trader, even that passage doesnt specify whether its okay to separate it into two separate CODES or DOCUMENTS. Ultimately, I think its clear the CFA wanted you to know to separate them, but separating the procedures and separating the documents is a fundamental difference.
Trader/God Wrote: ------------------------------------------------------- > Page 95: > http://www.cfapubs.org/doi/pdf/10.2469/ccb.v2005.n > 3.4000 > > “Commingling compliance procedures in the firm’s > code of ethics will diminish > the goal of reinforcing with the firm’s employees > their ethical obligations. > Stand-alone codes of ethics should be written in > plain language and address > general fiduciary concepts, unencumbered by > numerous detailed procedures > directed to the day-to-day operation of the firm. > In this way, codes will be most > effective in stressing to employees that they are > in positions of trust and must act > with integrity at all times. > > Separating the codes of ethics from compliance > procedures will also reduce, > if not eliminate, the legal terminology and > boilerplate language that can make > the underlying ethical principles incomprehensible > to the average person. Above > all, the principles in the codes of ethics must be > accessible and understandable > to everyone in the firm to ensure that a culture > of ethics and integrity is created > rather than merely a focus on attention to the > rules.” > > T/G Nice! This explains why there was such confusion. If I remember correctly, the question is whether or not it is OK to combine the CFA code with the firm’s code. According the this, you should not combine a code of ethics with compliance procedures. So I see no contradiction. Who knows though.
Yeah, I don’t think it was compliance…I thought it was firm ethics. Maybe, F it.
Trader/God Wrote: ------------------------------------------------------- > Page 95: > http://www.cfapubs.org/doi/pdf/10.2469/ccb.v2005.n > 3.4000 > > “Commingling compliance procedures in the firm’s > code of ethics will diminish > the goal of reinforcing with the firm’s employees > their ethical obligations. > Stand-alone codes of ethics should be written in > plain language and address > general fiduciary concepts, unencumbered by > numerous detailed procedures > directed to the day-to-day operation of the firm. > In this way, codes will be most > effective in stressing to employees that they are > in positions of trust and must act > with integrity at all times. > > Separating the codes of ethics from compliance > procedures will also reduce, > if not eliminate, the legal terminology and > boilerplate language that can make > the underlying ethical principles incomprehensible > to the average person. Above > all, the principles in the codes of ethics must be > accessible and understandable > to everyone in the firm to ensure that a culture > of ethics and integrity is created > rather than merely a focus on attention to the > rules.” > > T/G I think this portion only mentions about commingling of firms compliance procedure and firms code of ethics. It has no relation whatsoever with CFA codes and standards.
If we can’t figure this question out after the fact with all our book something is VERY wrong with CFAI’s testing. Really, really, wrong.
Trader/God Wrote: ------------------------------------------------------- > Page 95: > http://www.cfapubs.org/doi/pdf/10.2469/ccb.v2005.n > 3.4000 > > “Commingling compliance procedures in the firm’s > code of ethics will diminish > the goal of reinforcing with the firm’s employees > their ethical obligations. > Stand-alone codes of ethics should be written in > plain language and address > general fiduciary concepts, unencumbered by > numerous detailed procedures > directed to the day-to-day operation of the firm. > In this way, codes will be most > effective in stressing to employees that they are > in positions of trust and must act > with integrity at all times. > > Separating the codes of ethics from compliance > procedures will also reduce, > if not eliminate, the legal terminology and > boilerplate language that can make > the underlying ethical principles incomprehensible > to the average person. Above > all, the principles in the codes of ethics must be > accessible and understandable > to everyone in the firm to ensure that a culture > of ethics and integrity is created > rather than merely a focus on attention to the > rules.” > > T/G This is in regards to different compliance prodecures!! The question was about combining Codes!!
thepinkman…strongly agree
It’s simple boys, and a couple girls. You’re NOT allowed to comingle the CFA patented, copyrighted, heavily tested, strongly entrusted, unencumbering, sexily confusing Code of Conduct or Ethics or whatever else with your company’s. BUT you CAN include it as an attachment and have a line in your company’s code saying that the attached CFA Code of Ethics or Conduct must be abided by. So this means that although you can’t mix them together, employees are to abide by the CFA’s code, if attached, along with whatever is in the company’s.
MattLikesAnalysis Wrote: ------------------------------------------------------- > It’s simple boys, and a couple girls. Simple? Are you sure?
You think the CFAI is going to let companies just throw in sections of their Codes into company codes. We got our postings deleted for creating text about exam questions that we recreated from memory because that is a violation. I’m pretty sure using their material is a violation without keeping it separate – so it can be worshipped as its own entity.
MattLikesAnalysis Wrote: ------------------------------------------------------- > You think the CFAI is going to let companies just > throw in sections of their Codes into company > codes. We got our postings deleted for creating > text about exam questions that we recreated from > memory because that is a violation. I’m pretty > sure using their material is a violation without > keeping it separate – so it can be worshipped as > its own entity. Point to a section in the Code of Ethics and Standards that supports your claim that CFAI will not let companies combine their own code with the CFA code. Did you read the posts above yours?
Ok ok. Maybe its not simple. and ok ok. Incorporate is a very vague word with 11 different definitions. And combine doesn’t necessary mean incorporate. and to respond to you Dwight, the post you responded to was more of a joke than anything. To me: Incorporate means to attach. I think the conclusion is that you can combine/incorporate, whether it be an attachment or be hashed up into a company’s codes, the difference doesn’t matter. my final statement being, i really need this question to be right on my end, but I’m concluding its not: I took combine as hashing up but realize now that it really doesn’t matter, combine could mean include or attach and make reference to. Over and out.
Well we agree to disagree then 
Glad it’s “finally settled.” 
from a practical view, it seem stupid if “combine the CFAI code with company code in one book for convenience” is a violation. Even if you combine them in one book, you can still state clearly which is which. so I don’t see any reason it is a violation.
You do not mix code with standard. That is what they are asking. There are no tricks here, 3 paragraphs in CFAI book is enough to cover this.
disptra Wrote: ------------------------------------------------------- > You do not mix code with standard. That is what > they are asking. There are no tricks here, 3 > paragraphs in CFAI book is enough to cover this. Read it again. The consensus is (and I agree) that the question was asking whether to combine the CFA Code with the Firm’s Code. There was no mention of compliance, which is what the CFAI book references.
Who cares. We’re talking about one ethics question. I can’t even remember what I put anyway. At the end of the day, if I’m ever in a position where I need to actually worry about this - then I’ll re-figure it out. Some of the questions from this test were worded terribly and others were taken from a two sentence segment in some obscure region of the texts. I can almost guarantee that I would have achieved the same exact score…if not HIGHER…if I hadn’t read any of the ethics material to begin with. What a joke.